July 19, 1999

The Honorable Charlene Barshefsky
United States Trade Representative
600 Seventeenth Street, NW
Washington, DC 20508

　
Dear Ambassador Barshefsky:

We oppose the Administration's current position at the World Trade Organization (WTO) favoring accelerated tariff phase-out for wood products. The proposed "Advanced Tariff Liberalization" (ATL) initiative for the timber industry, which is part of the "early harvest" agenda for completion at the upcoming WTO ministerial meeting in Seattle, carries highly uncertain and potentially damaging consequences for the environment. We ask that the U.S. withdraw its support for this proposal and develop an environmentally justifiable alternative that has been subjected to thorough environmental impact analysis, and that gives priority to conserving forests, and not simply treating them as commodities.

Forest destruction is an enormous problem internationally. A report issued this spring by the World Commission on Forests and Sustainable Development noted:

Over the last two decades of the 20th century, rapid deforestation has taken its toll - some 15 million hectares of forests are lost annually, largely in the tropics. It is also clear that the structural integrity of much of the forest cover that remains has deteriorated.

The Commission called for urgent action, including major shifts in public policy, to reverse the global forest crisis.

Accelerated tariff phase-out for wood products would not correct, and could very well compound, worldwide forest destruction. According to American Forest and Paper Association officials, a recent study conducted by the Finnish consulting firm Jaakko Poyry estimated a three to four percent increase in forest products consumption as a result of tariff-free trade. Tariff elimination could thus magnify global consumption trends projected by the Food and Agriculture Organization of the United Nations, which, in its State of the World's Forests: 1999 report, forecast a 25 percent increase in worldwide industrial wood production and consumption by the year 2010.

The U.S. should also reject any forest products negotiations that threaten to treat legitimate conservation measures as illegal "non-tariff trade barriers," for example by attempting to build new restrictions into the WTO agreements on Sanitary and Phytosanitary Measures (SPS) and Technical Barriers to Trade (TBT). We would object to any new trade rules that might provide a basis for successful WTO dispute challenges against legitimate domestic measures for protection of health and the environment, such as regulations to prevent entry of invasive, exotic pests through wood imports. Similarly, the U.S. should make clear that it would vigorously oppose any negotiations that could lead to restrictions on legitimate third party certification and ecolabeling of forest products, or otherwise on the consumer's right-to-know about the environmental conditions under which wood products are logged and produced.

We would welcome the opportunity to work with the Office of the United States Trade Representative and others in the Administration on crafting a U.S. position that serves both trade and environmental objectives. Development of such a position could be informed by lessons learned from tariff reductions and other measures already agreed under the Uruguay Round agreements, and might consider, among other issues:

1. Elimination of perverse subsidies, identified in the World Commission on Forests and Sustainable Development report as a driving force behind global forest destruction;

2. Elimination of tariff escalations that retard sustainable development, especially for less developed countries;

3. Favorable treatment for trade in products originating from socially and environmentally responsible forest management systems; and

4. Dedication of revenues associated with expanded international commerce, for example through a small fee on cross-border trade in wood products, to provide funding for projects that help combat the world forest crisis, as well as for programs to monitor and curtail illegal trade in forest products.

Unfortunately, it appears that alternatives such as these have been ignored in the rush to promote wholesale, accelerated elimination of wood product tariffs. It is encouraging that USTR and the Council on Environmental Quality are undertaking an environmental analysis of the ATL in preparation for the WTO ministerial meeting. However, we believe it will not be possible to conduct a sufficient analysis in the time remaining before the Seattle ministerial, and so we urge the Administration to suspend its participation in the forest products negotiation until such an analysis has been completed.

Moreover, to assure an analysis with the appropriate depth, widespread public participation and a thorough evaluation of alternatives, we urge strongly that the forest products tariffs issue be analyzed through an environmental impact statement process that takes fully into account disciplines such as those required under the National Environmental Policy Act.

Thank you for considering our views on this crucial issue. We hope you will promptly suspend further promotion of the current U.S. position on wood product tariffs, and will begin development of an alternative trade policy that demonstrably enhances forest conservation and sustainable development.
 

Sincerely,

Antonia Juhasz
Director, International Trade & Forests Program
American Lands Alliance

David Downes
Senior Attorney, Trade & Investment Program
Center for International Environmental Law

William Snape, III
Legal Director
Defenders of Wildlife

J. Martin Wagner
Director, International Program
Earthjustice Legal Defense Fund

Stephan Schwartzman
Senior Scientist
Environmental Defense Fund

Andrea Durbin
Director, International Department
Friends of the Earth

William Mankin
Director
Global Forest Policy Project

Scott Paul
Senior Forest Policy Specialist
Greenpeace U.S.A.

Victor Menotti
Director, Environment Program
International Forum on Globalization

Daniel P. Beard
Senior Vice President for Public Policy
National Audubon Society

Jake Caldwell
Program Coordinator, Trade & Environment
National Wildlife Federation

Justin Ward
Senior Policy Specialist
Natural Resources Defense Council

A. Paige Fischer
Director, International Trade Program
Pacific Environment and Resources Center

Daniel A. Seligman
Director, Just Trade Program
Sierra Club

Michael A. Francis
Director, National Forest Program
Wilderness Society

David K. Schorr
Director, Sustainable Commerce Program
World Wildlife Fund
 

cc
Vice President Albert Gore Hon. Carol Browner
Hon. George Frampton Hon. Dan Glickman
Hon. Frank Loy Hon. David Sandalow
John Audley, EPA Ian Bowles, CEQ
Jennifer Haverkamp, USTR